What we collect, why we collect it, and what we never do with it

Your financial life is private. We treat the information you share with us the way we would want our own treated — with care, with discretion, and with a clear understanding of where it goes and where it does not. This policy describes the information Breiter Wealth Management, LLC collects, the reasons we collect it, the limited circumstances under which we share it, and the rights you have over it.

Last updated: June 25, 2026.

This policy applies to information collected through this website and through the advisory relationship. It is part of a pair with our Disclosures page, which covers fiduciary duty, compensation, conflicts of interest, and the Marketing Rule. Together they describe how we operate and how we protect what you trust us with.

This policy applies to three groups of people whose information we may collect:

• Clients. Individuals and households who have signed an advisory agreement with BWM. The federal privacy rules that apply most directly to this group are Regulation S-P under the Gramm-Leach-Bliley Act and the related provisions of the Investment Advisers Act of 1940.
• Prospective clients. Individuals who have contacted us, scheduled a meeting, or otherwise begun a conversation about becoming a client.
• Website visitors. Anyone who visits breiterwealth.com or its subdomains, whether or not they ever contact us. The protections that apply to this group come primarily from state privacy laws (including the California Consumer Privacy Act, as amended by the California Privacy Rights Act) and from our own internal standards.

The information we collect, and the rights you have over it, differ across these three groups. We describe each below.

From clients and prospective clients, the nonpublic personal information we collect includes:

• Identifying information. Name, address, phone number, email address, date of birth, Social Security number or other taxpayer identification number, marital status, and household composition.
• Financial information. Account numbers and balances, investment holdings and transactions, income sources and amounts, employment information, retirement plan and pension details, insurance policy information, loans and liabilities, real estate and other assets, beneficiary designations, and tax-return information you choose to share with us.
• Planning information. Goals, risk tolerance, time horizon, expected expenses and one-time outlays, charitable intentions, estate-planning wishes, and other details you share to help us build your plan.
• Information about household members. Where a plan covers a spouse, partner, dependent, or other household member, similar information about those individuals as it is relevant to the planning engagement.

From website visitors, we may collect:

• Contact-form submissions. The name, email address, phone number, and message you provide when you fill out a contact form, schedule a call, or request information.
• Login credentials for clients who access the client portal — email address and a hashed password. We never store passwords in plaintext.
• Server logs. Standard server logs automatically record IP address, browser type, device type, referring URL, pages requested, and timestamps. These are used for security, fraud prevention, and basic site operation.
• Cookies and similar technologies. The client-portal area of this site uses session cookies that are strictly necessary to keep you signed in while you are using it. The public marketing pages do not currently load third-party analytics, advertising, or social-media tracking pixels. [Paul: confirm — if BWM later adds analytics (e.g., Google Analytics, Plausible, Fathom) or any third-party pixel, this section is updated to disclose what is loaded, what it measures, and how visitors can opt out. Recommended default is privacy-respecting analytics (Plausible or Fathom) that do not require a cookie banner.]

We collect information from three kinds of source:

• Directly from you. The information you provide on intake forms, in meetings, on the phone, by email, and through documents you upload to the client portal.
• From your transactions with us and our custodian. Account balances, transaction histories, performance reports, and tax-reporting information generated by your accounts at Charles Schwab & Co., Inc. or any subsequent custodian.
• From service providers and authorized third parties. Information from your other financial institutions when you authorize them to share data with us, information from your tax preparer or attorney when you direct us to coordinate with them, and information from data-aggregation services you connect to your plan (such as account-aggregation tools used to consolidate held-away assets).

We collect personal information only for purposes connected to providing investment advisory and planning services. Those purposes are:

• To provide advice. Building and updating financial plans, investment recommendations, tax-planning analyses, estate-coordination work, and the day-to-day advice clients hire us for.
• To manage accounts. Opening accounts with our custodian, processing contributions and withdrawals, placing trades, generating performance reports, and administering the advisory relationship.
• To meet legal and regulatory obligations. Anti-money-laundering checks, identity verification, IRS reporting, SEC recordkeeping, and similar obligations imposed on registered investment advisers.
• To protect against fraud and unauthorized access. Security monitoring, identity verification before sensitive actions, and investigation of suspected unauthorized activity.
• To communicate with you. Sending statements, plan deliverables, meeting confirmations, regulatory disclosures (including this policy and our Form ADV), and educational content you have asked to receive.

We do not collect personal information to sell it. We do not collect more than we need.

We do not sell client information. We do not rent it. We do not share it with marketers, data brokers, or any third party for their own marketing purposes.

We share information only as needed to provide the services clients have engaged us for, or as required by law. The recipients fall into four categories:

• Our custodian.Charles Schwab & Co., Inc. holds client assets and processes transactions. We share the information Schwab requires to open and maintain accounts. Schwab's own privacy practices govern the information you provide directly to them and the information they generate about your account.
• Service providers we use to run the firm. Technology platforms, planning-software vendors, customer- relationship-management software, secure document storage, email and calendaring infrastructure, e-signature providers, and the hosting providers behind this website. Each provider is contractually obligated to handle client information solely for the purpose for which it was provided and to maintain appropriate safeguards. [Paul: confirm — final list of named subprocessors for the public privacy policy. Current candidates include the custodian (Charles Schwab & Co., Inc.), website hosting (Vercel Inc.), client-portal and authentication backend (Supabase Inc.), planning software, CRM, e-signature, and secure document storage. Industry practice is to either name the categories without naming each vendor, or to publish a current subprocessor list at a stable URL. Please advise which approach BWM prefers.]
• Professionals you authorize. When you direct us to coordinate with your accountant, attorney, insurance agent, or another professional, we share what is needed for that coordination and nothing more. We do this on your written authorization, which you can revoke at any time.
• Regulators, courts, and law enforcement. Where required by law, subpoena, court order, regulatory examination, or other legal process. Where the law permits, we will tell you about a legal demand for your information before responding to it.

Joint marketing arrangements. BWM does not engage in joint marketing arrangements with other financial institutions.

Affiliates. BWM has no affiliated companies. We do not share information with affiliates because there are none.

Your right to limit sharing.Because BWM shares nonpublic personal information only as described above — that is, only as permitted by Regulation S-P's exceptions for servicing, processing, joint-account administration, legal compliance, and similar purposes — clients do not have a separate right to opt out of these uses under Regulation S-P. If we ever propose to share information outside these categories, we will give you the opportunity to opt out beforehand, in writing.

We maintain a written information security program designed to protect client information against unauthorized access, alteration, disclosure, and loss. The program covers three categories of safeguard:

• Administrative safeguards. Written policies and procedures, role-based access (employees and contractors get access only to the information they need to do their job), background checks on personnel with access to client information, mandatory training on privacy and cybersecurity, and a documented incident-response plan.
• Technical safeguards. Encryption of data in transit (TLS/HTTPS across the website and the client portal) and at rest, multi-factor authentication on the administrative systems that hold client information, hashed password storage in the client portal, audit logging, continuous security monitoring, and prompt patching of known vulnerabilities.
• Physical safeguards. Locked physical storage of any paper records, secure disposal (shredding) of records no longer needed, and physical-access controls at any office where client information is handled.

Breach response. If a security incident affects the confidentiality of nonpublic personal information, we will notify affected individuals and the appropriate regulators as required by Regulation S-P and applicable state-law breach-notification statutes. [Paul: confirm — Reg S-P amendments adopted by the SEC in May 2024 require covered advisers to provide individual notice to affected persons as soon as practicable but not later than 30 days after discovery of unauthorized access to or use of customer information that is reasonably likely to result in substantial harm or inconvenience. Compliance date for SEC-registered advisers in the smaller-entity bucket is December 3, 2026. Please confirm BWM's compliance-date bucket and whether this section should explicitly cite the 30-day notice rule.]

No system is perfect. We take reasonable steps to protect your information. We cannot promise that no system anywhere will ever be breached. If one ever is, we will tell you what we know, what we are doing about it, and what you should consider doing.

SEC rules require investment advisers to keep certain books and records for specified periods — generally five years from the end of the fiscal year in which a record is created, with the first two years in an easily accessible location, and longer in some cases (firm-formation documents and partnership records for the life of the firm plus three years).

We follow those requirements. For records not subject to a specific retention rule, we keep client information only as long as is necessary for the purposes described in this policy, or as required by tax law, other legal obligations, or the legitimate needs of an active or recently active advisory relationship. [Paul: confirm specific retention schedule by record type if BWM's written policies define one. Default disclosure language above is consistent with Advisers Act Rule 204-2.]

When you stop being a client, the same standards continue to apply to whatever information we retain. We do not start treating former-client information more loosely than current- client information.

An important note for residents of California and other states with comprehensive privacy laws: most of the information described in this policy concerns the financial relationship between BWM and its clients, and that information is generally exempt from state consumer-privacy laws under the carve-out for information already governed by the Gramm-Leach-Bliley Act. The protections of Regulation S-P, described above, govern that information.

State consumer-privacy laws do apply to information we collect through this website from visitors who are not clients (for example, the contact information you provide through a contact form), and to other categories of personal information not covered by the GLBA exemption. For that information, residents of California, Colorado, Connecticut, Utah, Virginia, and other states with comprehensive privacy laws generally have the following rights:

• The right to know what personal information we have collected about you, where we got it, why we have it, and with whom we have shared it.
• The right to access a copy of the personal information we hold about you.
• The right to correct inaccurate personal information.
• The right to delete personal information, subject to exceptions where we are required to keep it (regulatory recordkeeping, active legal matters, fraud prevention).
• The right to opt out of the sale or sharing of your personal information. BWM does not sell personal information, and does not share it for cross-context behavioral advertising. There is nothing for you to opt out of, but the right exists if our practices ever change.
• The right to non-discrimination. We will not deny services, charge a different price, or provide a different level of service because you exercised a privacy right.

How to exercise these rights. Send a written request to info@breiterwealth.com or call (636) 373-9300. We respond within 45 days where the law requires it, and faster when we can. We may need to verify your identity before responding, particularly for requests to access or delete.

Authorized agents. A resident may submit a request through an authorized agent. We will require the agent to provide signed permission from you and we may contact you directly to confirm.

This website is intended for adults considering or maintaining an advisory relationship with BWM. It is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If a parent or guardian believes a child has submitted personal information through this site, please contact info@breiterwealth.com and we will delete it.

Where a financial plan covers minor beneficiaries (for example, 529 college savings or UTMA accounts for clients' children or grandchildren), the limited information about those minors is provided by the adult client, used solely for the planning purpose, and protected under this policy.

Under Regulation S-P, registered investment advisers ordinarily owe each client an annual notice of their privacy practices. Federal law provides an exception: an adviser is not required to send an annual notice if the adviser has not changed its privacy practices since the last notice and does not share nonpublic personal information with non-affiliated third parties other than as permitted by the servicing-and-processing exceptions of Regulation S-P.

BWM intends to rely on that exception. We will provide a fresh privacy notice when (a) a client first engages us, (b) we make a material change to our privacy practices, or (c) any client asks for one. The current version of this policy is always available at breiterwealth.com/privacy.

We update this policy when our practices change, when the law changes, or when we find a clearer way to say what we mean. The “Last updated” date at the top of the policy tells you when the current version went into effect.

For changes that materially affect how we collect, use, or share client information, we will notify clients directly — by email, by mail, or through a prominent notice in the client portal — before the change takes effect.

Questions about this privacy policy, requests under state privacy laws, and any concern about how your information has been handled can be directed to:

Breiter Wealth Management, LLC
info@breiterwealth.com
(636) 373-9300

We respond to privacy questions within two business days, and to formal requests under state privacy law within the statutory window — typically 45 days, extendable once where the law allows.

For matters that concern fiduciary duty, compensation, conflicts of interest, the Marketing Rule, or anything else not covered by this policy, see our Disclosures page.

Breiter Wealth Management, LLC is a registered investment adviser. Registration does not imply a certain level of skill or training.